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21-104771-Response Letter-01-21-2022-V1 January 21, 2022 Job No. 1886-001-016-0016 Mr. Jim Harris Senior Planner City of Federal Way 33325 8th Ave S Federal Way, WA 98003 RE: Woodbridge Business Park (City File #17-105489-UP) Shoreline Substantial Development Permit (21-104771) Dear Mr. Harris: This letter is written on behalf of Federal Way Campus, LLC to provide additional information to the Notice of Incomplete Application received from AHBL dated December 22, 2021. The applicant is seeking to expand the existing road, Weyerhaeuser Way S, by approximately 9 feet as a condition of approval for the Woodbridge Business Park project. Approximately 225 LF of this expansion of Weyerhaeuser Way S falls within the 200-foot Shoreline Management Zone surrounding North Lake. The area of impact by the road expansion, within the Shoreline Management Zone is 2,676 SF and will require approximately 360 CY of fill material. Please see the site plan attached with this application for further details. The expansion is necessary to meet frontage improvements anticipated to be required by the City under the Woodbridge Business Park application, currently under review (City File #17- 105489). Decisional Criteria (FWRC 15.05.150(3) In an effort to provide concise and direct responses, we have copied the code sections below in italics and added our responses in bold. (3) A substantial development permit shall be granted by the director only when the development proposed is consistent with the following: (a) Goals, objectives, policies, and use regulations of Federal Way shoreline master program; Goal 1. Shoreline areas shall permit a variety of development types in accordance with the FWRC, FWCP, and Shoreline Master Plan designations. Designs, densities, and locations for all allowed uses and developments should consider physical and natural features of the shoreline and prevent a net loss of shoreline ecological functions. Mr. Jim Harris January 21, 2022 Page 2 The proposed project will follow the type of development required by the Federal Way Comprehensive Plan: Weyerhaeuser Way as a principal collector. The required road expansion has been designed in a way that considers the physical and natural features of the shoreline. The applicant is proposing to split the expansion required between two parcels. SMPP69 Develop standards, buffers, and mitigation requirements for designated critical areas in the shoreline consistent with city-wide regulations. The project proposes to follow mitigation requirements. The mitigation techniques for the project are described in the “Critical Areas Mitigation Plan” by Wet.land, dated September 2021. The plan can be found with this submittal. All new development and activity in or adjacent to shoreline areas should be designed, constructed, and operated as to avoid significant adverse impacts to ground or surface water quality. Use of state and local best management practices and guidance should be implemented to avoid significant adverse impacts to water quality. The project has been designed to avoid significant adverse impacts to ground water quality. See “Preliminary Technical Information Report” by ESM Consulting Engineers, dated November 2021. SMPP95 New surface transportation development should be designed to provide the best possible service with the least possible infringement upon shoreline areas. The road expansion was designed to provide a symmetrical cross section, which will also create the least possible infringement on the shoreline area. The design splits the required expansion in half. SMPP100 Shoreline circulation routes should provide for non-motorized means of travel and should incorporate multimodal provisions where public safety can be assured. The expansion of Weyerhaeuser Way will lead to the addition of bike lanes to the existing road. The expansion will also allow for the installation of 8’ wide sidewalks with a planter as a separation between motorized traffic. (b) Federal Way comprehensive plan and city code; and The Federal Way Comprehensive Plan- Transportation Chapter (Map III-4) designates Weyerhaeuser Way S as a principal collector (Type K). Weyerhaeuser Way is currently developed as a 60’ wide right-of-way (ROW). However, the principal collector standard requires a 78’ wide ROW. Therefore, in order for the project to meet FWRC 19.135.230, the project must expand the road by 9’ on each side of the existing road. A portion of the required expansion falls within the 200-foot Shoreline Management Zone. (iv) Transportation and parking facilities. Allowed within urban conservancy designated areas under the requirements imposed by FWRC 15.05.080(5)(a)(v). Mr. Jim Harris January 21, 2022 Page 3 The road expansion will be developed consistently with the transportation element of the Federal Way comprehensive plan (FWCP) and designed to provide the best service with the least possible impact on shoreline ecological function. (c) The policies, guidelines, and regulations of the Shoreline Management Act (Chapter 90.58 RCW and Chapters 173-26 and 173-27 WAC). The proposed road expansion follows the policies, guidelines, and regulations of the Shoreline Management act (Chapter 90.58 RCW and Chapters 173-26 and 173-27 WAC). If you have any questions, please feel free to contact me at 253-838-6113, and I look forward to your response. Sincerely, ESM CONSULTING ENGINEERS, LLC ERIC G. LaBRIE, A.I.C.P. President i:\esm-jobs\1886\001\016-0016\document\letter-022.docx